July 27, 2006

The Department of Homeland Security announced a new initiative yesterday to help businesses do a better job of ensuring that their workforces are made up of authorized workers.  IMAGE (“ICE Mutual Agreement between Government and Employers”) offers increased collaboration between the Immigration & Customs Enforcement agency of DHS and private employers to reduce employment of undocumented workers.  The IMAGE program requires that employers agree to:  1) receive federal training; 2) submit to an ICE I-9 audit; 3) register and use the Employment Verification Program; and 4) adhere to a list of ICE “Best Business Practices” that includes:

  • creation of internal training programs for employment verification;
  • establishment of regular I-9 audits by neutral parties;
  • creation of protocols for Social Security no-match letters;
  • creation of an employee “tip line” to report violations;
  • creation of safeguards to prevent unlawful discrimination;
  • self-reporting of violations to ICE;
  • regular assessment of adherence to Best Practices by subcontractors;
  • annual reports to ICE on effectiveness of program.